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18 May 2000 Internal T.I. 2000-0006037 F- FRAIS D'ACQUISITION-- summary under Subsection 18(9.02) Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(9.02) limited scope of proposed s. 18(9.02) Regarding life insurance policy acquisition expenses, including commissions directly related to the acquisition of the policy, incurred by an insurer, CCRA noted that proposed “subsection 18(9.02) … applies only to life insurance policies referred to in paragraph 1401(1)(b) of the Income Tax Regulations (after 1995- 1404(3)(C)) and to certain damage insurance policies referred to in subsection 1400(3)”. ...

10 October 2006 Internal T.I. 2006-0169051I7- Successor Pool Issues-- summary under Subsection 66.7(5) Summary Under Tax Topics- Income Tax Act- Section 66.7- Subsection 66.7(5) Given that the successor provisions concern income attributable to " production from the particular property", rather than income attributable to the "particular property", a taxpayer may deduct its successored resource pools against income from a particular successor property (e.g., a lease) that has only arisen as a result of development of the property after the successoring of the resource pools, even though the further development could itself be regarded as giving rise to a new form of Canadian resource property (the oil or gas well). ...

Repairs or Running Expense leasing commissions currently deductible In finding that commissions paid by a trust owning rental buildings to leasing agents were currently deductible rather than being additions to Class 13 (as claimed by the trust, a non-resident, on disposing of the building, the Directorate cited Canderel and stated (TaxInterpretations translation) that the commissions: gave rise only to short term advantages – immediate or at most limited to the term of the lease. ...

. … [T]he transfer pricing rules in section 247… would generally not be applied to adjust the amount of rent under the circumstances…. ...

., … the copyright ownership test) or the definition of "accredited production" in subsection 125.5(1)…. ...

Consequently…the corporation must make an adjustment on Schedule 1 of the … T2 in order not to include the results of the business attributable to the period of three days in the calculation of its income for the taxation year deemed to end on 31 December 2010. ...

However, should it lose its exempt status, it also would lose its CDA under s. 89(1.2) – and the timing of the capital gains arising to it under the s. 149(10) disposition of its property would preclude those gains from being added to the available amount of its CDA. ...

CRA responded: [T]he interest expense incurred by the taxpayer in respect of dental services is not an expense paid to a medical practitioner, dentist or nurse or a public or licensed private hospital … [and] those interest expenses do not qualify for the medical expense tax credit pursuant to paragraph 118.2(2)(a). ...

The Directorate noted that the shares’ market price could “fluctuate greatly,” and indicated that the TSO accordingly might: conclude that such portion of the proceeds of disposition for the Mining Properties by the Vendor is not determinable prior to the date of issuance of the shares by the Purchaser and that such portion of the proceeds of disposition would be recognized for tax purposes at the times of their issuance …. ...

., CRA stated: [T]his subsidy is not income from a source to be included in computing income under paragraph 3(a) and is not required to be included in computing the income of the recipient under any other provisions …. ...